State v. Parker

In State v. Parker, 315 N.C. 222, 337 S.E.2d 487 (1985), the Supreme Court of North Carolina expanded the type of corroboration which may be sufficient to establish the trustworthiness of the confession in cases in which independent proof is lacking but where there is substantial independent evidence tending to establish the trustworthiness of the confession. In State v. Parker, 268 N.C. 258, 150 S.E.2d 428 (1966), the North Carolina Supreme Court found the evidence of defendant's breaking and entering with the intent to commit a felony and larceny insufficient to send the charge to the jury. A men's clothing store was broken into and five suits were taken. Although a witness testified that he saw "a person who looked just like the defendant drop something on the train tracks," id. at 262, 150 S.E.2d at 430, near the clothing store, the witness could not positively identify the defendant as the man he had observed. Another witness later recovered a suit belonging to the store on the nearby train tracks. Despite these witnesses, no evidence placed the defendant in the store at the time of the breaking and entering or established that the stolen suits were in his possession. The North Carolina Supreme Court held that the evidence offered was insufficient to support the indictment and reversed the lower court's decision to deny the defendant's motion for nonsuit.